The Department of Economic Development, Jobs, Transport and Resources would like your feedback about proposed changes to activities under the Victorian Energy Efficiency Target (VEET) scheme, also known as the Energy Saver Incentive (ESI).
The VEET scheme
The Victorian Energy Efficiency Target (VEET) scheme is a market-based scheme that incentivises energy efficiency upgrades, reduces greenhouse gas emissions, encourages investment and jobs and develops technology in Victoria.
The Victorian Government is strengthening the scheme. As part of this, a number of changes tothe VEET Regulations 2008 are being proposed. These changes aim to improve access to existing energy saving activities and to ensure that all activities are correctly rewarded.We would like your feedback about these proposed changes.
We will consider your feedback on these changes before any Regulation amendments are made.
Overview of proposed amendments
The proposed amendments would change the number of Victorian Energy Efficiency Certificates (VEECs) that are awarded for three VEET activities. These are:
- underfloor insulation
- weather sealing
- high efficiency televisions.
Please note: there are several other consultation processes underway to do with the VEET scheme. Please see the last page of this document for a list of current VEET consultation processes or go to energyandresources.vic.gov.au/esi for further information and submission deadlines.
Why are these changes being proposed?
There are two main reasons for these proposed changes. These are explained below.
Removing barriers
There are some scheme activities that have not been implemented as much as they could be for reasons that are largely to do with the way the current regulation is written. Some of the proposed amendments to the regulations seek to remove barriers to implementation.
Significant changes
There are some kinds of VEET activities that have undergone significant market or technological change. Some of the assumptions in the calculations to do with the amount of greenhouse gas emissions that these activities reduce or avoid therefore need bringing up-to-date. In all cases, the greenhouse gas coefficients used for converting electricity and gas energy savings into greenhouse savings have been updated to reflect the current values.
Underfloor insulation (Schedule 12)
The three main changes proposed for underfloor insulation are:
- reducing the required minimum R-value for underfloor insulation from R2.5 to R1.5
- removing conductive insulation products from being an eligible VEET product
- separating the insulation of enclosed and unenclosed subfloors into two different activities.
Reducing the required R-value for underfloor insulation from R2.5 to R1.5
Subfloor spaces have restrictions which can make it challenging to install insulation to an
R-value of R2.5. The requirement under VEET that underfloor insulation be R2.5 has created a barrier to implementing this activity. For most Victorian homes, R1.5 underfloor insulation is sufficient to create significant greenhouse gas savings. It is therefore proposed that the required R-value for underfloor insulation be reduced to R1.5.
Removing conductive insulation products from being an eligible product under the VEET scheme
Subfloors often contain electrical wiring. In some circumstances wiring may become degraded or damaged. If conductive insulation products are installed in subfloors with damaged wiring the insulation can become electrically live, causing a safety issue. It is therefore proposed that conductive insulation products no longer be an eligible product under the scheme.
Separating the insulation of enclosed and unenclosed subfloors into two different activities
Subfloor spaces, which are unenclosed and therefore largely exposed to the outside weather conditions, are a greater source of heat loss in winter than enclosed subfloor spaces, where airflow through the subfloor space is restricted. In order to recognise the greater energy saving achieved when installing underfloor insulation in an unenclosed subfloor it is proposed that this activity be divided into two activities with different abatement factors:
- Schedule 12A – Insulating an enclosed subfloor
- Schedule 12B – Insulating an unenclosed subfloor
The proposed amendments define an enclosed subfloor as an underfloor space that is not exposed to external weather conditions other than by vents.
Table 1: proposed changes to abatement factors for underfloor insulation
Current abatement factor / Proposed abatement factors0.073 / Enclosed subfloor 0⋅05
Unenclosed subfloor 0.099
How would the number of certificates for this activity be affected?
It is expected that the reduction in the required R-value would result in more houses being able to install underfloor insulation under the scheme, as this will lower the installation cost. The proposed changes would decrease the number of certificates for installing insulation in enclosed subfloor spaces but would increase the number of certificates for unenclosed subfloor spaces.
Certificates for activity = Floor area in m2 x Abatement Factor x Regional Factor
Example: Underfloor insulation for 160m2 of uninsulated subfloor in Melbourne/Mild location
Regional factor / Abatement factor / Squaremetres / Certificates / Rounded
Current / = / 1.06 / x / 0.073 / x / 160 / = / 12.38 / 12 VEECs
Proposed
Enclosed subfloor / = / 1.06 / x / 0.05 / x / 160 / = / 8.48 / 8 VEECs
Proposed
Unenclosed subfloor / = / 1.06 / x / 0.099 / x / 160 / = / 16.79 / 17 VEECs
Questions:
Do you have any comments on these proposals?
Are there any other issues that we have not considered?
Weather sealing (Schedule 15)
Several changes are proposed for this activity: updating and clarifying wording for weather sealing measures;specifying required product lifetimes;changes to abatement and regional factors and the introduction of a new weather sealing activity.
The base heating and cooling loads used in the original certificate creation algorithms were recently reviewed. It was recommended that abatement factors and regional factors for some measures be adjusted.
In the current VEET Regulations the guidance on measurement specifications and product specifications for weather sealing activities are very general. It is proposed to define these more clearly where possible.
Deemed activities calculate the number of VEET certificates to be awarded based on the number of years for which any given product is likely to be installed. For the majority of Schedule 15 products, it is proposed that products must be capable of lasting for at least ten years of normal use.Where products have a shorter lifetime this is outlined in the Regulations.
It is proposed that the ESC be given the power to assess and approve whichproducts can be used for weather sealing measures.
It is proposed that a new measure be added for ducted evaporative cooling system outlet coversas a new activity:15H.
Weather sealing external door (Schedule 15A)
The intention of this measure is the complete draught sealing of an external door.At present the Regulation is written in such a way that it allows for either a draught arrestor or just weather stripping to be fitted. Some such measures do not result in the complete draught sealing of a door. Given that the number of certificatesthat are awarded is based on the assumption of full draught sealing it is proposed that the wording relating to this activity be revised accordingly so that it ensures that air flow is restricted around the entire door perimeter.In addition, it is proposed that products must be capable of lasting for at least ten years of normal use.
Certificates for activity = Abatement Factor x Regional Factor
Current certificate allocation
Air sealing measure / Unit / Abatement factorWeather sealing external door (15A) / Per door weather sealed / 0.371
Location / Regional factor
Melbourne / Mild / 1.03
Regional Victoria / Mild / 0.91
Regional Victoria / Cold / 1.30
Regional Victoria / Hot / 0.84
Proposed certificate allocation
Air sealing measure / Unit / Abatement factorWeather sealing external door (15A) / Per door weather sealed / 0.605
Location / Regional factor
Melbourne / Mild / 1.05
Regional Victoria / Mild / 0.84
Regional Victoria / Cold / 1.32
Regional Victoria / Hot / 0.69
How would the number of certificates for this activity be affected?
The proposed changes would create more certificates per installation. This is due to:
- updateddata relating to theenergysavings which can be achieved with regard to average heating and cooling loads in Victorian houses when this measure is undertaken
- updated climate zone data.
Assumptions concerning the mix of heating and cooling equipment found in Victorian houses have also been updated to reflect changes which have taken place since 2008, and the greenhouse coefficients used for electricity and gas savings have been updated to the latest values.
The proposed change to the regional factors would result in the Melbourne/Mild and the Regional/Cold locations receiving slightly more certificates, and the Regional/Mild and the Regional/Hot locations receiving slightly fewer.
Example:Installation of 15A in Regional/ Mild location
Regional factor / Abatement factor / Number installed / Certificates / RoundedCurrent / = / 0.91 / x / 0.371 / x / 2 / = / 0.67 / 1 VEEC
Proposed / = / 0.84 / x / 0.605 / x / 2 / = / 1.02 / 1 VEEC
What equipment specification changes are proposed?
It is proposed that the ESC be given the power to assess and approve which products can be used for weather sealing measures. It is proposed that product specification for 15A change to require the complete draught sealing of an external door in such a way that it ensures that air flow is restricted around the entire door perimeter and that the product must be capable of lasting for at least ten years of normal use.
Weather sealing external window (Schedule 15B)
This measure covers the permanent installation of a product onto an external window in such a way that it ensures that air flow is restricted between the window frameand all openable parts of the window, but which nonetheless does not impair the proper operation of the window.
The proposed change to 15B is that any product installed be designed in such a way as to restrict the airflow into or out of the premises through a window as well as through the window frame. It is also proposed that products be capable of lasting for at least ten years under normal circumstances. It is proposed that the Regulation be changed so that the number of certificatesthat are awarded is based on the assumption that any product installed on an external window restricts airflow through that window and that itshould not impair the normal operation of the window.
Certificates for activity = Abatement Factor x Regional Factor
Current certificate allocation
Air sealing measure / Unit / Abatement factorWeather sealing external window (15B) / Per m2 of window weather sealed / 0.025
Location / Regional factor
Melbourne / Mild / 1.03
Regional Victoria / Mild / 0.91
Regional Victoria / Cold / 1.30
Regional Victoria / Hot / 0.84
Proposed certificate allocation
Air sealing measure / Unit / Abatement factorWeather sealing external window (15B) / Per m2 of window weather sealed / 0.027
Location / Regional factor
Melbourne / Mild / 1.05
Regional Victoria / Mild / 0.84
Regional Victoria / Cold / 1.32
Regional Victoria / Hot / 0.69
How would the number of certificates for this activity be affected?
The proposed changes would create a slight alteration to the number certificates per installation. The rationale for this isexplained on page 4. The changes are mainly due to updating of the mix of heating and cooling appliances, and revision of the greenhouse gas coefficients.
Example: Installation of 15B in Regional/Cold location
Regional factor / Abatement factor / Squaremetres / Certificates
per m2
Current / = / 1.30 / x / 0.025 / x / 1 / = / 0.0325
Proposed / = / 1.32 / x / 0.027 / x / 1 / = / 0.035
What equipment specification changes are proposed?
It is proposed that the ESC be given the power to assess and approve which products can be used for weather sealing measures and that the product specification change to require that products used be capable of lasting for at least ten years of normal use.
Replacing existing exhaust fan with self-sealing exhaust fan (Schedule 15C)
This weather sealing measure covers the installation of a ceiling or wall exhaust fan that has an integral self-closing damper that substantially restricts air flow through the exhaust fan when the fan is not operating. It is proposed that the products be capable of lasting for at least ten years of normal use and thatthey must expel air either to the outside or into the roof space of the premises.
Certificates for activity = Abatement Factor x Regional Factor
Current certificate allocation
Air sealing measure / Unit / Abatement factorReplacing existing exhaust fan with self-sealing exhaust fan (15C) / Per exhaust fan / 0.911
Location / Regional factor
Melbourne / Mild / 1.03
Regional Victoria / Mild / 0.91
Regional Victoria / Cold / 1.30
Regional Victoria / Hot / 0.84
Proposed certificate allocation
Air sealing measure / Unit / Abatement factorReplacing existing exhaust fan with self-sealing exhaust fan (15C) / Per exhaust fan / 0.928
Location / Regional factor
Melbourne / Mild / 1.05
Regional Victoria / Mild / 0.84
Regional Victoria / Cold / 1.32
Regional Victoria / Hot / 0.69
How would the number of certificates for this activity be affected?
The proposed changes would create a slight alteration to the number of certificates awarded per installation. The rationale for this is explained on page 4. The changes are mainly due to updating of the mix of heating and cooling appliances, and revision of the greenhouse gas coefficients.
Example:Installation of 15C in Regional/Hot location
Regional factor / Abatement factor / Number installed / Certificates / RoundedCurrent / = / 0.84 / x / 0.911 / x / 1 / = / 0.77 / 1 VEEC
Proposed / = / 0.69 / x / 0.928 / x / 1 / = / 0.64 / 1 VEEC
What equipment specification changes are proposed?
It is proposed that the ESC be given the power to assess and approve which products can be used for weather sealing measures and that the product specification change to require that products used be capable of lasting for at least ten years of normal use.
Installing a cover with self-closing damper on existing exhaust fan (Schedule 15D)
This weather sealing measure rewards the installation of a cover with self-closing damper on an existing exhaust fan. The main change proposed is that products be installed according to the manufacturer’s instructions and be capable of lasting for at least ten years of normal use.
Current certificate allocation
Air sealing measure / Unit / Abatement factorInstalling a cover with self-closing damper on existing exhaust fan (15D) / Per exhaust fan / 0.911
Location / Regional factor
Melbourne / Mild / 1.03
Regional Victoria / Mild / 0.91
Regional Victoria / Cold / 1.30
Regional Victoria / Hot / 0.84
Proposed certificate allocation
Air sealing measure / Unit / Abatement factorInstalling a cover with self-closing damper on existing exhaust fan (15D) / Per exhaust fan / 1.798
Location / Regional factor
Melbourne / Mild / 1.05
Regional Victoria / Mild / 0.84
Regional Victoria / Cold / 1.32
Regional Victoria / Hot / 0.69
How would the number of certificates for this activity be affected?
The proposed changes would almost double the number of certificates awarded per installation.
The rationale for this is explained on page 4. The main reasons for this are that the average heating/cooling load savings from the installation of a cover has increased, updating of the mix of heating and cooling appliances, and revision of the greenhouse gas coefficients.
Example: Installation of 15D in Regional/Cold location
Regional factor / Abatement factor / Number installed / Certificates / RoundedCurrent / = / 1.30 / x / 0.911 / x / 1 / = / 1.18 / 1 VEEC
Proposed / = / 1.32 / x / 1.798 / x / 1 / = / 2.37 / 2 VEECs
What equipment specification changes are proposed?
It is proposed that the ESC be given the power to assess and approve which products can be used for weather sealing measures, and that the product specification change to require that products used be capable of lasting for at least ten years of normal use.
Sealing wall vents (Schedule 15E)
This weather sealing measure covers the installation of a product which seals a wall vent.The main change proposed is that products be capable of lasting for at least ten years of normal use and be made of a robust non-shrinking permanent sealing material. It is proposed that products should either be designed and manufactured specifically for this purpose or be approved by the Essential Services Commission. The calculations are based on the assumption that the product is installed on an unsealed wall vent inside the dwelling.
Current certificate allocation
Air sealing measure / Unit / Abatement factorSealing wall vents (15E) / Per wall vent / 0.231
Location / Regional factor
Melbourne / Mild / 1.03
Regional Victoria / Mild / 0.91
Regional Victoria / Cold / 1.30
Regional Victoria / Hot / 0.84
Proposed certificate allocation
Air sealing measure / Unit / Abatement factorSealing wall vents (15E) / Per wall vent / 0.236
Location / Regional factor
Melbourne / Mild / 1.05
Regional Victoria / Mild / 0.84
Regional Victoria / Cold / 1.32
Regional Victoria / Hot / 0.69
How would the number of certificates for this activity be affected?
The proposed changes to this activity would create a slight alteration to the number certificates per installation. The rationale for this is explained on page 4. The changes are mainly due to updating of the mix of heating and cooling appliances, and revision of the greenhouse gas coefficients.
Example:Installation of 15E in Melbourne/Mild location
Regional factor / Abatement factor / Number installed / Certificates / RoundedCurrent / = / 1.03 / x / 0.231 / x / 10 / = / 2.38 / 2VEECs
Proposed / = / 1.05 / x / 0.236 / x / 10 / = / 2.48 / 2VEECs
What equipment specification changes are proposed?
It is proposed that the ESC be given the power to assess and approve which products can be used for weather sealing measures, and that the product specification change to require that products used be capable of lasting for at least ten years of normal use.
Installing chimney damper to open fireplace – permanent and temporary
(Schedule 15F and proposed new Schedule 15G)
At present the Regulations simply specify that products installed under this activitybe capable of restricting air flow into or out of a chimney or flue. However, the majority of items installed under 15F have been chimney balloons. The Regulations were intended to cover products that lasted at least ten years. It is therefore proposedthat this schedule be split so as to calculate abatement based on the lifetime of the product.
The proposed changes to 15F are that it require permanent installations that restrict the airflow into or out of a chimney or flue when closed but which allow the fireplace to operate safely and effectively when open. It is proposed that these products have a manufacturer’s rated lifetime of at least ten years under normal circumstances.